MULTIPLE ADMISSIBILITY OF EVIDENCE UNDER THE PHILIPPINE RULES OF COURT
(Rule 130 on Admissibility of Evidence; Focus on the Concept of Multiple Admissibility)

1. OVERVIEW AND DEFINITION

Multiple admissibility refers to the principle that a piece of evidence may be admissible for more than one purpose. In other words, evidence that might be objectionable if offered for a certain purpose may nonetheless be received if it is offered for (or is relevant to) a different, proper purpose. Once admitted, it may serve all admissible purposes, provided these are consistent with the rules on relevancy and competency, and subject to any limiting instruction that the court may give.

This concept is anchored on the fundamental rule that all evidence that is relevant, competent, and not otherwise excluded by law or rules should be admitted. If a piece of evidence meets the requirements for admission for at least one legitimate purpose—despite any objections that might apply to another purpose—it can still be received in evidence for that allowable purpose. This is often encapsulated by the rule:

“Evidence is not rendered inadmissible merely because it is inadmissible for one purpose, if it is admissible for another purpose.”

2. LEGAL BASIS IN THE PHILIPPINES

The doctrine of multiple admissibility is rooted in the general principles on relevancy and competency under the Rules of Court. Specifically:

Rule 128 (“General Provisions”) sets out the basic principles of relevancy, competency, and the scope of evidence.
Rule 130 (“Rules of Admissibility”) governs when evidence may be admitted.
Rule 132 (“Presentation of Evidence”) and Rule 133 (“Weight and Sufficiency of Evidence”) also inform how evidence is introduced and evaluated.

Although the 2019 Amendments to the Rules of Evidence (which took effect in 2020) reorganized and updated certain provisions, the principle of multiple admissibility generally remains the same: if a piece of evidence is relevant and competent for one purpose, it should be admitted even if it might not be admissible for another purpose.

3. RATIONALE

Promotion of Truth-Seeking
Courts aim to ascertain the truth and resolve disputes equitably. Excluding relevant evidence merely because it may be inadmissible for one specific purpose could hamper the court’s truth-seeking function.
Efficiency and Fairness
The principle recognizes that evidence often has multiple facets of relevance. Prohibiting its admission outright may deprive the court of probative material that can shed light on the facts in issue.
Flexibility and Judicial Discretion
Philippine courts maintain broad discretion in ruling on admissibility. Evidence may come with complexities—documents or testimonies can speak to different issues in a case. Rather than mechanically excluding such evidence, the court can tailor its admission subject to an instruction limiting the purpose for which the evidence may be considered.

4. EXAMPLES OF MULTIPLE ADMISSIBILITY

Prior Statements
- Impeachment vs. Substantive Evidence: A witness’s prior inconsistent statement may not always be admissible as substantive evidence (i.e., to prove the truth of the matter stated), but it could be admissible for impeachment (to challenge the witness’s credibility). In some instances, the same statement may also qualify as a party admission if it meets the rules’ requirements, making it admissible for the truth of the matter asserted as well.
Character Evidence
- Generally, character evidence is not admissible to prove a person’s conduct on a specific occasion. However, the same evidence may be admissible:
  - In civil cases, if character is an issue (e.g., libel or defamation suits).
  - In criminal cases, for certain exceptions (e.g., the character of the accused being in issue if introduced by the defense, or character of the complainant in sex-related offenses under specific conditions).
- If a piece of character evidence straddles these different grounds, it might be received for one permissible purpose but not for the other.
Documents Proving Multiple Facts
- A document (e.g., a contract) may be introduced to prove both the existence of a contractual relationship and the authenticity of a signature in dispute. Even if authenticity were not in issue (or if some portions are objectionable under the hearsay rule), it could still be admitted to prove the relationship of the parties.
Evidence of Motive vs. Independent Relevant Conduct
- A prior act by the accused might be inadmissible purely to show criminal disposition (which is prohibited), but it could be admitted to show motive, intent, plan, preparation, opportunity, knowledge, or other specific exceptions under the “similar acts” or “similar occurrences” doctrine.

5. LIMITING INSTRUCTIONS

Because evidence admitted under multiple admissibility can confuse or prejudice the jury (in jurisdictions with juries) or even the judge (in a bench trial), courts typically give limiting instructions or clarifications in their decisions. Limiting instructions remind the trier of fact that:

The evidence is only to be considered for one or more specific purposes for which it is admissible.
It must not be used for an inadmissible purpose.

In the Philippine setting—where trials are bench trials (the judge is both the trier of law and fact)—the judge is presumed to be guided by law and able to distinguish between proper and improper uses of a given piece of evidence. Nonetheless, in certain scenarios, the adverse party may request that the court make a specific notation or resolution limiting the scope of how the evidence is considered.

6. OBJECTIONS AND WAIVER

Timely Objection: If a party believes a piece of evidence should not be admitted for a certain purpose, that party must timely object to its admission and specify the grounds.
Failure to Object: If no objection is raised, the evidence—whether or not it is entitled to probative weight—becomes part of the court’s consideration.
Motion for Exclusion or Limitation: The party may also move that the court admit the evidence solely for a specified purpose. If the offering party is clear in specifying the purpose for which the evidence is introduced, the court will rule on that basis.

7. SELECTED JURISPRUDENCE AND DOCTRINAL STATEMENTS

While Philippine case law discussing “multiple admissibility” often appears in the context of specific evidentiary issues (such as extrajudicial confessions, prior statements, or documentary evidence introduced for multiple ends), the principle can be gleaned from longstanding jurisprudence. Some general principles from Supreme Court rulings include:

Relevance and Competence Override: Philippine courts underscore that evidence relevant to a fact in dispute should not be excluded merely because it would be inadmissible if offered for another reason (e.g., hearsay or speculative if used to prove a different fact).
Balancing Test: The court may exclude evidence—even if relevant—if its probative value is outweighed by the danger of undue prejudice, confusion of issues, or waste of time. However, if these concerns can be managed by proper limiting instructions, the court will admit the evidence for the permissible purpose.
Res Inter Alios Acta and Exceptions: The bar against using acts/declarations by others who are not parties to the case (res inter alios acta) might preclude certain uses of the evidence, yet the same evidence may be admissible for another acceptable purpose (e.g., to establish motive or knowledge).

8. PRACTICAL CONSIDERATIONS FOR LAWYERS

Identify All Possible Bases
When offering evidence, counsel should clarify all permissible grounds for admission. If one ground is contested or faces exclusion, another ground might save the evidence.
Request for Limiting Instruction
If adverse evidence is admitted on multiple grounds, counsel should request the court to limit its use to the grounds strictly permissible. This helps protect the client from prejudice.
Drafting Pleadings and Motions
In pleadings such as formal offers of evidence, identify the specific purpose(s) for each exhibit or testimony. This clarity helps avoid confusion and strengthens your position on appeal.
Anticipate Objections
Prepare to address how the evidence is relevant for at least one allowable purpose if the opposing party objects to its introduction.
Preserve the Record
For appellate review, ensure the court’s ruling, your objections, and any limiting instructions are fully documented in the transcript or records of the proceedings.

9. ETHICAL CONSIDERATIONS

Candor Toward the Tribunal: A lawyer must not mislead the court by offering evidence under a false pretense. If you represent a client and know that certain evidence is not admissible for a proposed purpose, you cannot ethically claim it is. However, if there is a valid alternative purpose, it is the lawyer’s duty to present it clearly and honestly to the court.
Respect for the Rights of Others: In some situations, insistence on admitting evidence that borders on being inadmissible or prejudicial may infringe the opposing party’s right to a fair hearing. The lawyer must ensure that all steps taken align with both procedural rules and ethical standards.
Avoiding Frivolous Arguments: Lawyers should avoid frivolous arguments for the sake of admitting evidence with minimal probative value. Multiple admissibility is not an “open sesame” for everything; relevance and competency remain central.

10. SUMMARY POINTS

Multiple admissibility means one piece of evidence can be admitted for more than one legitimate purpose under the Rules.
If evidence meets the standard for at least one lawful purpose, it cannot be excluded solely because it is inadmissible for a different purpose.
Limiting instructions ensure that the trier of fact considers the evidence only for the permissible purpose(s).
Proper advocacy requires clearly stating and defending all possible bases for admitting or excluding evidence and seeking protective measures if necessary.
The principle promotes fairness, efficiency, and the truth-seeking function of the courts.

FINAL NOTE

The doctrine of multiple admissibility is a cornerstone of Philippine evidence law, ensuring that the courts have access to all relevant and competent proof. While it broadens the avenues for presenting evidence, it also demands that lawyers practice thoroughness, precision, and ethical clarity—identifying permissible grounds, properly raising objections, and obtaining limiting instructions where needed. By understanding and applying this principle correctly, counsel can effectively advocate within the confines of the Rules of Court and uphold the integrity of judicial proceedings.